Guided Choice Asset Management, Inc. (“GCAM”), in business since 1999, is a wholly owned subsidiary of GuidedChoice.com, Inc., collectively known as “GuidedChoice.” GuidedChoice operates under two brand names, GuidedChoice and 3Nickels. GCAM developed the engine that powers the services offered by these brands. The GuidedChoice brand is focused on retirement wellness, engaged in the business of designing and developing retirement plan advice and management software and retirement income planning software, and marketing the related products and services. GuidedChoice provides services via a web-based digital interface primarily to defined contribution plans and directly to participants in defined contribution plans (such as a 401(k) plan) and other types of employee benefit plans, and to customers of financial services companies, as well as retail investors. Similar services are also provided to financial institutions as a sub-advisor. The 3Nickels brand is focused on financial wellness, providing a suite of digital tools designed to help individuals strategically plan and invest to achieve multiple financial goals, as well as get answers to questions about their money in the areas of: investments, goals, college, budgeting, loans, credit cards, medical, house, gifts, cars, debt, and retirement. 3Nickels provides services via mobile app primarily to retail customers, participants in employee benefit plans, and customers of financial services companies. Under the GuidedChoice Brand Provider Level Investment Selection Services Given a universe of investments by an institutional provider of plan services, we will select a subset of investments that meet defined criteria, which may include requirements established by the plan provider. The objective is to obtain a list of screened investments that meet the requirements of the plan sponsor for asset class diversification, performance, expenses, risk, and portfolio construction. The investments are monitored quarterly to ensure they continue to meet the criteria and changes are made within any recordkeeping system constraints. Plan Level Services Investment Policy Statement We provide plan sponsors an investment policy that outlines the process used for selecting investments to be used within a qualified plan. The statement includes, but is not limited to, the method used to determine and attain diversification amongst the investments and the selection and ongoing monitoring processes for investments. Investment Selection Based on the plan sponsor’s objectives as stated in the Investment Policy Statement, we will select a line-up of investment options for the plan that will include a broad range of asset classes. In addition, the plan sponsor may elect to choose additional investments, such as company stock or a self-directed brokerage option. The objective is to provide enough diversification to enable the plan’s participants to invest efficiently. Investment Monitoring If outlined in the Investment Policy Statement or Participant Agreement, we will monitor the investment line-up on a periodic basis to ensure that the investments are continuing to match the stated objectives. A report will be provided to the plan sponsor outlining the metrics of the investments, including but not limited to, performance, risk measurements, expenses, and style analysis. The report may also include an analysis of the investment options. Retirement Readiness Analysis Based upon the retirement benefits provided by the employer, including Social Security, we can provide a projection of the plan’s participants’ retirement readiness. We will project a range of income at retirement for each employee based upon the assets currently in the employer’s retirement benefit plans, expected future contributions and earnings, and Social Security. A Retirement Readiness Report, as described below, can be provided to each employee. Individual Level Services Guidance & Advice Individuals may use our advice and management service for accumulation and/or our retirement income planning service for distribution, our digital tools, a call center, or a paper-based solution to access personalized guidance. Individuals who have received and accepted a disclosure agreement may obtain advice through our digital tools, call center, or a paper-based solution. This service includes a projection of a potential range of income at retirement based upon the current value of any retirement assets included, expected future contributions and earnings, and Social Security. Based upon the retirement goal established, we may recommend changes to the savings rate, investment allocation, risk level, and retirement age. Then we will provide a projected range of income at retirement based upon the new parameters. Investment Constraints. Certain specific investments may be excluded from our recommendations either by the individual, or in certain cases, by the plan or plan provider. We will take the excluded investments into account when calculating projections, as well as when making an investment allocation recommendation. Company Stock. A plan sponsor may include company stock as an investment option in a defined contribution plan. If a participant owns company stock in the account, the participant, or in certain cases the plan or plan provider, may elect to exclude it from the asset allocation; although, we will take into account the company stock when making an allocation recommendation. If it is not excluded, we will include it in the asset allocation recommendation, which may result in the inclusion or exclusion of company stock in the allocation. The recommendation will comply with any plan restrictions on selling company stock. Brokerage Account. A plan sponsor may include a brokerage account as an option in the plan. GCAM has established electronic communication links with certain financial institutions to enable data exchange with regard to the underlying investments held in the brokerage account. In addition, the participant can enter those investments into our software. We will take the investments into consideration when making the investment allocation recommendation. Investment Recommendations. We provide advice on the specific investment options available to an individual. Within a qualified plan, those investments generally include open-ended mutual funds, money market funds, stable value funds, exchange listed securities, separate and commingled trusts, real estate investment trusts, guaranteed investment contracts, and variable and fixed annuities. In addition, we may take into account additional investments held outside a qualified plan for purposes of projections and possibly buy/sell recommendations. These include, but are not limited to, passbook savings accounts, certificates of deposit, closed-end mutual funds, privately held securities, corporate, government, and municipal bonds, real estate, and commodities. Implementing Advice. The individual using our advice services elects whether or not to implement the advice. GCAM has established electronic communication links with certain plan providers and financial institutions to facilitate data exchange and transactions. An individual may be able to implement and transmit the investment directions and savings rate changes to those institutions. Ongoing Analysis. Where GCAM has established electronic communication links with plan providers and financial institutions, when the individual revisits our digital services, some account and investment data may be updated automatically. The individual should review and ensure that all data is updated. Failure to do so may materially affect the relevance of the advice provided. Personalized Spending Report. For those individuals using the retirement income planning service (usually at or in retirement), a personalized report is generated that indicates from which accounts to liquidate to provide for the required retirement income need. The recommendation takes into account tax efficiencies when determining from which accounts to liquidate. Managed Account In a managed account, GCAM is responsible for managing an individual’s investments within the account. The investments used by GCAM in the managed account are those that are made available to the individual, typically through a retirement plan. An individual can elect to discontinue participating in a managed account at any time. Investment Constraints. Certain specific investments may be excluded from our recommendations either by the individual or in certain cases, by the plan or plan provider. We will take the excluded investments into account when calculating projections, as well as when making an investment allocation recommendation. Company Stock. A plan sponsor may include company stock as an investment option in a defined contribution plan. If a participant owns company stock in the account, the

participant may elect to exclude it from the asset allocation, although we will take into account the company stock when making an allocation recommendation. If the participant does not exclude it, we will include it in the asset allocation recommendation, which may result in the inclusion or exclusion of company stock in the allocation. The recommendation will comply with any plan restrictions on selling company stock. Brokerage Account. A plan sponsor may include a brokerage account as an option in the plan. GCAM has established electronic communication links with certain financial institutions to enable data exchange with regard to the underlying investments held in the brokerage account. In addition, the participant can enter those investments into our software. We will take the investments into account when making the investment allocation recommendation. Investment Recommendations. We provide advice on the specific investment options available to an individual. Within a qualified plan, those investments generally include open-ended mutual funds, exchange traded funds, money market funds, money market deposit accounts, stable value funds, exchange listed securities, separate and commingled trusts, real estate investment trusts, guaranteed investment contracts, and variable and fixed annuities. In addition, we may take into account additional investments held outside a qualified plan for purposes of projections and possibly buy/sell recommendations. These include, but are not limited to, passbook savings accounts, certificates of deposit, closed-end mutual funds, privately held securities, corporate, government and municipal bonds, real estate, and commodities. Ongoing Analysis. Where GCAM has established electronic communication links with plan providers and financial institutions, when the individual revisits our digital services, some account and investment data may be updated automatically. The individual should review and ensure that all data is updated. Failure to do so may materially affect the relevance of the advice provided and may adversely impact the managed account. Personalized Spending Report. For those individuals using the retirement income planning service (usually at or in retirement), a personalized report is generated that indicates from which accounts to liquidate to provide for the required retirement income need. The recommendation takes into account tax efficiencies when determining from which accounts to liquidate. Periodic Account Review. Ongoing, GCAM will review the individual’s account and make investment allocation changes automatically to ensure the appropriate risk level based upon the individual’s investment objectives. Usually, rebalancing takes place quarterly but no less often than annually. The individual agrees and authorizes GCAM to execute transactions without prior approval to meet the selected objectives. Annual Report. Each individual in a managed account receives an annual projection of their potential range of income at retirement, based upon the current value of any retirement assets included in the digital interface, expected future contributions and earnings, as well as Social Security. Opt-In. Individuals enroll in a managed account by actively selecting to participate. This may be through the advice and management or retirement income planning services, our digital services, a call center, or a paper-based solution. Opt-Out. Eligible participants are enrolled in a managed account in accordance with rules established by the plan or plan sponsor. Individuals enrolled can elect to discontinue the managed account at any time. The individual gives GCAM discretionary authority to determine an investment allocation for the individual and manage the allocation until the individual elects to discontinue the managed account. Individuals, who have received and accepted a disclosure agreement, may use the advice and management and/or retirement income planning services, our digital services, a call center, or a paper-based solution to access the personalized advisory and managed account services. This service includes a projection of a potential range of income at retirement based upon the current value of any retirement assets included, expected future contributions and earnings, and Social Security. Based upon the retirement goal established, we may recommend changes to the savings rate, investment allocation, risk level, and retirement age. Then we will provide a projected range of income at retirement based upon the new parameters. The individual may modify any of the recommendation to meet personal preferences. We will then provide a projected range of income at retirement based upon the modified parameters. GCAM will then manage the account based upon the selected risk level target. Retirement Readiness Report Based upon the retirement benefits provided by the employer, including Social Security, we can provide a projection of the plan’s participants’ retirement readiness. We will project a range of income at retirement for each employee based upon the assets currently in the employer’s retirement benefit plans, expected future contributions and earnings, and Social Security, as well as other known assets in certain circumstances. Sub-advisory Services GCAM has arrangements with financial institutions to provide services as a sub- advisor. GuidedChoice.com, Inc. or GCAM may license technology and provide other services to financial institutions to enable them to provide their own advisory and managed account services. In addition, GCAM may provide the investment allocation to be used for individuals’ managed accounts within another advisory platform. Client Assets Managed As of December 31, 2023, for individuals in retirement plans, GCAM directly managed $6,645,705,545 in discretionary assets. Under the 3Nickels Brand Subscription-based Advice Version Individuals who download our mobile app or use the web interface and agree that they have received and accept a disclosure agreement get access to personalized guidance and advice. 3Nickels includes the establishment of three standard financial goals: retirement income, debt pay-off, and emergency fund. Individuals can include additional financial goals, determine the priority of all goals, and receive advice on how they may achieve them. Advice includes a projection of a potential range of income at retirement based upon the current value of any retirement assets included, expected future contributions and earnings, and Social Security. Based upon the goals entered, we may recommend changes to the retirement plan savings rate, investment allocation, risk level, and retirement age, as well as adjustments to budgetary spending. A projected range of income at retirement based upon the new parameters will also be provided and all goals will include an indication of whether or not the individual is on-track to meet them. Investment Constraints. Certain specific investments may be excluded from our recommendations by the individual. We will take the excluded investments into account when calculating projections, as well as when making an investment allocation recommendation. Company Stock. If a participant owns company stock in a defined contribution plan account, the participant may elect to exclude it from the asset allocation; although, we will take into account the company stock when making an allocation recommendation. If it is not excluded, we will include it in the asset allocation recommendation, which may result in the inclusion or exclusion of company stock in the allocation. Investment Recommendations. We provide advice on the specific investment options available to an individual, provided the user enters them into the interface. Within qualified plans, those investments generally include open-ended mutual funds, money market funds, stable value funds, exchange listed securities, separate and commingled trusts, real estate investment trusts, guaranteed investment contracts, and variable and fixed annuities. In addition, we may take into account additional investments held outside a qualified plan for purposes of projections and possibly buy/sell recommendations. These include, but are not limited to, passbook savings accounts, certificates of deposit, closed-end mutual funds, privately held securities, corporate, government and municipal bonds, real estate, and commodities. Implementing Advice. The individual using advice services elects whether or not to self-implement the advice. Ongoing Analysis. When the individual revisits our digital services, some account and investment data may be updated automatically through the use of account aggregation services. The individual should review and ensure that all data is updated. Failure to do so may materially affect the relevance of the advice provided.